Comment on Medicare pay proposal by September 14
Medicare’s public comment window on the 2027 Physician Fee Schedule closes Sept. 14, and more than 44,000 comments are already on file. Practices that want a say in what their rates look like on Jan. 1 have less than a week to write one.
The Numbers and the Changes
The proposal, file code CMS-1848-P, runs 716 pages and published in the Federal Register on July 16. Comments must be received by Sept. 14, 2026, not simply postmarked by then, and CMS will weigh them as it writes the final rule.
The headline number is the conversion factor. The rule projects a 1.68 percent decrease for clinicians who are not qualifying participants in an advanced alternative payment model and a 1.19 percent decrease for those who are, a swing CMS lays out in its fact sheet on the proposed rule.
The cut is not the only thing worth a comment. CMS also proposes to reduce payment for a separately identifiable office visit billed the same day as a procedure, rewrite how indirect practice expense is allocated, cap year-over-year practice expense swings at 5 percent, tighten who may furnish remote monitoring services and phase traditional MIPS into MIPS Value Pathways.
Filing the Comments
CMS lists exactly three channels in the rule and asks commenters to choose one. The simplest is electronic. Open docket CMS-2026-2377 on Regulations.gov and follow the submit a comment instructions. You can type the comment in the box or attach it as a file, and you can file as an individual, on behalf of an organization or anonymously.
Regular mail goes to Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, P.O. Box 8016, Baltimore, MD 21244-8016. Express or overnight mail goes to the same attention line at Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850. Whichever route you pick, reference file code CMS-1848-P.
What Counts and What Doesn’t
CMS discourages duplicate submissions but says it will post acceptable comments from multiple unique commenters even when the content is identical or nearly identical. Signing a specialty society’s form letter is not wasted effort. It is also not the same as telling the agency something it does not already have.
Name the section of the rule you are answering, then bring numbers only your practice has: how many same-day evaluation and management visits you billed last year, what the practice expense rewrite does to your three highest-volume codes, how many staff hours a new reporting requirement would add. Specifics survive the sort. Outrage does not.
Practices that rely on the Federal Register for guidance often find the sheer volume of proposed changes overwhelming. It is easy to feel that one voice cannot sway the outcome when the agency is already processing thousands of similar inputs. However, the agency’s process relies on the aggregate of these specific data points to adjust the final rule. If every affected provider submits their unique operational data, the final numbers may shift in a way that better reflects the reality of patient care rather than a theoretical calculation.
Privacy and Public Record
Everything you send is public. CMS posts every comment it receives before the window closes, including any personally identifiable or confidential business information inside it. Strip patient details, cut anything you would not want a payer or a competitor reading and assume the comment is permanent.
If the rule is finalized as proposed, most of it takes effect Jan. 1, 2027.
